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    Accrued interest under mercantile accounting taxed in the accrual year; reopening upheld on tangible material, not change of opinion.
    Third-party seized material needs corroboration; JDA-linked receipts cannot be taxed as income from other sources without transfer analysis.
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      No overlapping proceedings under Section 6(2)(b) were...

      CGST search, sealing and provisional attachment upheld where statutory remedies were available and taxpayer did not cooperate.

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      GSTJune 4, 2026Case LawsHC
      No overlapping proceedings under Section 6(2)(b) were established, because the petitioner did not show that any other competent authority had already initiated action on the same subject matter. The Court held that search and seizure under Section 67, including sealing of premises when required, and provisional attachment under Section 83 were within the CGST framework. It further held that statutory remedies existed for release of seized goods and de-sealing, yet the petitioner bypassed those remedies and did not cooperate with summons or the investigation. In these circumstances, the availability of an alternative efficacious remedy barred interference under Article 226, and the writ petition was dismissed.

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      ActsIncome Tax